ML20112E892
| ML20112E892 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/11/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-85-011, KMLNRC-85-11, OL, NUDOCS 8501150300 | |
| Download: ML20112E892 (26) | |
Text
,_ _
~4 KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY J
@LENN LKOESTER rect restsicase7. souctsan January 11, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. R.D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 85-011 Re:
Docket No. STN 50-482 OL Subj: Changes to FSAR Description of Quality Program Gentlemen:
10CFR50.55 requires that after March 11, 1983, each Construction Permit holder may change a previously accepted Quality Assurance Program description included in the Final Safety Analysis Report, provided the change does not reduce the commitments in the program previously accepted by the NRC.
Attached are changed pages to the Wolf Creek operating Quality program described in the Wolf Creek Final Safety Analysis Report. The attach-ment also describes 1) the reason for the change, and 2) the basis for concluding the change does not reduce KG&E commitments in the operating Quality program previously accepted by the NRC.
This information will be formally incorporated into the next revision of the Wolf Creek Final Safety Analysis Report. The information is hereby incorporated into the Wolf Creek Generating Station, Unit No. 1, Operating License Application.
Yours very truly, dh 1
O Glenn L. Koester Vice President - Nuclear GLK bb Attach xc: PO'Connor (2), w/a HBundy, w/a V
l g
i 201 N. Market -WIcNts, Kansas - Men Address: PO. Box 208 I Wictuta, Kansas 67201 - Telephone: Area Code (316) 2616451
'9 OATH OF AFFIRMATION STATE OF KANSAS
)
)
SS:
COUNTY OF SEDGWICK )
I, Kent R. Brown, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal for Glenn L. Koester, Vice President -
Nuclear of Kansas Gas and Electric Company, know the contents thereof, and that all statements contained therein are true.
KANSAS CAS AND ELECTRIC COMPANY By
^
Kent R. Brown Group Vice President-Technical Services E. D. Prothro, Assistant Secretary STATE OF KANSAS
)
)
SS:
i COUNTY OF SEDGWICK )
i BE IT REMEMBERED that on this lith day of January, 1985
, before
,me, Evelyn L. Fry, a Notary, personally appeared Kent R. Brown, Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed the foregoing instru-ment, and he duly acknowledged the exacucion of the same for and on behalf of and as the act and deed of said Corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the
,,,,,,,,d,atq and year above written.
'h.h*'-
M~
nudn 41
\\.,.i. p Vcir" ' /ct. "*c#cv(/
' x_... yc;.
,... n
' 7l (diumission expires on August 15, 1985
~,
Revisions to the Final Safety Analysis Report Addendum and the reasons for the revisions are shown on a number basis next to the modified text.
The numbers correspond to the reasons given below:
.1.
Reason for Change This change reflects the newly created position of Director of Engineering and Technical Services.
B' asis for Concluding the Change Does Not Reduce KG&E Commitments The change does not revise responsibilities relating to the Quality Program.
2.
Reason for Change The Configuration Control Board and Quality Assurance Committee have been eliminated.
Basis for Concluding the Change Does Not Reduce KG&E Commitments The functions performed by these groups will be perfor.ned by others during the normal review cycle.
3.
Reason for Change This change clarifies the Plant Nbnager's duties relating to preservice and inservice inspection.
Basis for Concluding the _ Change Does Not Reduce KG4E Commitments No progree change has been made.
b-
.5 M-
't. r, a ' k
.4 R yeen fer Chinga 1
The section is being revised to disallow the use of the " conditional release" process for nonconforming items required for Technical 4
Specification Operability. Such items may only be released for use through the completion of a Plant Modification Request.
Also, to incorporate ANSI N18.7, Section 5.2.14 requirement regarding re-inspection of items after " repair" or " rework."
4
{
Justification:
This is an increase in the quality Assurance progras in that it will
. require appropriate controls for the release of Tech. Spec. required
. items including Engineering and Safety Evaluations, consideration of i'
impact on other operating and design doctroents, review for Licensing 4
j commitments, etc. Also, to comply with ANSI N18.7, Section 5.2.14
. requirement.
5.
- Reason for Change Section is being revised to clearly identify when each of the WCGS nonconformance doctments (i.e. Nonconformance Report, Work Requests and Deficient Docunent Notices) shall be utilized.
Justification s This is a clarification change to the existing commitment and enhances i
rather than decreases the KG5E Quality Assurance Program.
6.
Reasoa for Change
.The Manager Management Systems no longer administers site QA records.
i Basis for Concluding the Change Does Not Reduce KG&E Commitments The function will still be performed. Only the individual responsible 2
for performing this function has changed.
- m.,
om
.) -
7 Reason'for Change ANSI N45.2.4, paragraph 3.3, (RG 1 30) and ANSI N45.2.8, paragraph 3.4.1, (RG 1.116) state that installation inspections or checks should be perfbrmed to verify protective measures have been maintained during storage for electrical and mechanical items respectively.
At Wolf Creek the adequacy of protective measures for items in storage is verified by Warehouse, Quality Control and Quality Assurance personnel on an audit / surveillance basis.
Basis for Concluding the Change Does Not Reduce KG&E Commitments These audit / surveillance checks, while not specific to every individual
. piece of equipment, provide adequate assurance that KG&E storage of these items is adequate.
8.
Reason for Change The Director Nuclear Operations currently holds the position of Wolf Creek Site Director.
Basis for Concluding the Change Does Not Reduce KG&E Commitments No program change has besn implemented. - The Director Nuclear Operations will perfbrm the duties of both positions until commercial operation. After commercial operation begins, the Site Director position will be eliuinated.
9 Reason for Change The change reflects recent revisions in the KG&E organization.
.v
Basis for Concluding the Change Does Not Reduce KG&E Commitments The Manager Quality First reports directly to the Group Vice President Technical Services to increase the independence of the organization.
The remainder of the changes either do not affect the Quality Program or are a clarification of the existance of a separate startup quality control group.
10.
Reason for Change This change clarifies the trend analysis of nonconformance doc umentation.
Basis for Concluding the Change Does Not Reduce KG&E Commitments The Quality Branch will be responsible for reviewing nonconformance reports for adverse Quality Program trends. Hardware malfunction failure analyses are conducted by KGSE Operations.
11.
Reason for Change The title of Wolf Creek Project Diretor has been changed to Wolf Creek Site Director.
Basis for Concluding the change Does Not Reduce KG&E Commitments The Quality related duties of this position have not been revised.
12.
Reason for Change This change expands the definition of a design document.
Justification No program change has been made.
n --
, ?,
,8 I
^ 1,
S 13 Reason for Change
/
st This change is required to be consistent with the Wolf Craek Technical Specit'ications.
/
Justifications Tne NSRC will also review fuel design changes. This will add to their
- s-I scope of reyiew.
- f g.,
4 14.
Reason for Change Section is being revised to define disposition categories per ANSI 5-45.2.10-1973 Existing categories are not consistent with comitment.
s Justification:
e This is an increase in the Quality Assure.ce program in that it defines disposition categories in accordance with ANSI 42.2.10-1973. These standard definitions will be used throughout the KG&E Nonounformance Progre.
i A
d
/
s I
s
&f-w'A-
?"
s f 7_$h -
+
>2 3-
> _ da.I 4
7-__
SNUPPS-WC r
~
REGULATORY GUIDE 1.30 REVISION O DATED 8/72 1
Quality Assurance Requirements for the Installation, Inspec-i tion, and Testing of Instrumentation and Electric Equipment (Safety Guide 30) a DISCUSSION:
with' major vendor's instruction manuals but KG&E concurs i
does not necessarily apply a signature of approval (ANSI N45.2.4, Section 3(2).
KG&E. uniquely identifies each safety-related' item of pro-cess control instrumentation.
This identification provides Traceability to calibration. data.
These actions are KG&E's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the persons who performed the calibration (ANSI N45.2.4, Section 6.2.1).
.At WCGS, the adequacy of protective measures for items in
~
f 7
storage is verified by warehouse, Quality Control and Quality Assurance personnel on an audit / surveillance basis
.(ANSI N45.2.~4,-Section 3.3).
REGULATORY GUIDE 1.33 REVISION 2 DATED 2/78 Quality Assurance Program Requirements (Operation) s DISCUSSION:
e
(
The recommendations of this guide and -the ANSI Standard $
listed in Table 17.2-3 are met except where specific alter-natives are indicated.
The provision to automatically incorporate. the latest issued ANSI standards as set out in the last paragraph of ANSI N18.7 is not adopted.
t REGULATORY GUIDE 1.37 REVISION O DATED 3/73 Quality Assurance Requirements for ' Cleaning of Fluid Sys-tems and Associated Components of Water-Cooled ' Nuclear Power Plants DISCUSSION:
KG&E complies with the ~ recommendations of ' this regulatory
. guide.
~
REGULATORY GUIDE 1.38 REVISION 2 DATED 5/77 Quality. Assurance Requirements for Packaging, Shipping,.
Receiving,. Storage, and. Handling of items for Water-Cooled L
Nuclear-Power Plants l
Rev. 15 3A-2 01/85 a 2 s m._
, m s.
s.-,,.
, - _ ~.,,,,,, _ _. _
.m,,
SNUPPS-WC REGULATORY GUIDE 1.111 REVISION 1 DATED 7/77 Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors DISCUSSION:
The recommendations of this regulatory guide are met.
Refer to Section 2.3.
REGULATORY GUIDE 1.113 REVISION 1 DATED 4/77 Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implement-ing Appendix I DISCUSSION:
The recommendations of this regulatory guide are met.
Refer to Section 11.2.
4 REGULATORY GUIDE 1.114 REVISION 1 DATED 11/76 Guidance on. Being Operator at the Controls of a Nuclear Power Plant DISCUSSION:
The recommendations of. this regulatory guide are met.
Refer to Section 13.1.
REGULATORY GUIDE 1.116 REVISION 0-R DATED 5/77
' Quality Assurance Requirements for ' Installation, Inspec-tion, -and Testing of Mechanical Equipment and Systems DISCUSSION:
KG&E complies with the recommendations of this regulatory
- guide with the clarification that at WCGS. the adequacy of protective measures for items in storage is verified by Warehouse, - Quality - Control and Quality Assurance personnel (9
on an. audit / surveillance basis (ANSI N45.2.8, Section 3.4.1).
REGULATORY GUIDE 1.123
_ REVISION 1 DATED 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants
- DISCUSSION:
KG&E complies with the recommendations of this regulatory guide.
Rev. 15 3A-6 01/85-m.
,.n,
-.r-en-,,---,,n
,an-,nwr
.-n--,,-e-=wer, - - -
-,,--,..r-,n
,,--p v~
~
SNUPPS-WC The Wolf Creek Site Director reports directly to the Vice l@
President - Nuclear.
Also reporting to the Vice President-Nuclear are the Director Quality and various support services functions.
The Vice President - Nuclear provides overall pro-gram direction on nuclear matters to several managers as shown in Figure 17.2-2.
17.2.1.3a
.olf Creek Site Director W
gg The Wolf Creek Site Director reports to the Vice President-lG)
Nuclear and has direct responsibility for construction, engi-neering and support for the Wolf Creek Generating Station, Unit No.
1.
The Wolf Creek day project direction to:
Site Director provides day-to-lC a.
Construction Manager b.
Director of Engineering and Technical Services b
c.
Plant Manager, and d.
Manager Startup The. Vice President - Nuclear and the Wolf Creek Site Direc-1O tor together with the management personnel listed above func-tion as a team to accomplish the design, construction and startup of the Wolf Craek Generating Station.
The Director
. Nuclear Operations currently holds the position of Wolf Creek l
Site Director.
After commercial director position will be eliminated. operation begins, -the site g
F 17.2.1 3b Director of Engineering and Technical Services
- The Director of Engineering and Technical Services reports 9
-directly to the Vice President-Nuclear and is responsible for providing overall program direction to the Manager Nuclear l Services, the Manager Nuclear Plant Engineering and the 7
Manager Management Systems.
17.2.1.3c. Manager Administrative Services l@
The Manager Administrative Services reports directly to-the l@
'Vice President - Nuclear and is responsible for providing staff human resource, administrative and technical assistance
'to the Vice President Nuclear.
In addition, the Manager Administrative Services oversees department staffing ef forts, aids -in achieving social. impact goals and provides guidance in ' application of policies to the work force.
The Nuclear coordinator-Technical, Supervisor Human Resources and Super-
~ visor Accounting Controls report to the Manager Administrative g
Services.
' 17.2.1.3d Manager Management Systems The Manager. Management-Systems reports directly to-the Director of Engineering and Technical Services and
-is l@
- responsible-for the Management Systems Program which includes - Configuration Management, Document Control, Records
' Management.
and Methods and Procedures and WCGS Policy / Directive. and General Procedure Modification Programs.
Rev. 15-p.
.w
+e.p w h.
,-c
_,s-.
.-=
i SNUPPS-WC In executing,his responsibilities, he develops, implements,
. maintains and monitors the implementation of procedures for configuration identification, control,. verification and status accounting; for document control; and for records management.y Through the - Records Management Programs, he provides for the capture of records generated during all phases of WCGS and is responsible for the receipt, encoding, data entry, microfilm-ing, storage, and retrieval of both commercial records and those required by applicable industry codes and standards.
Through the Systems and Procedures Program, He develops and/or provides aid in the development of management procedures and performs coordination of management policies / directives and procedures for the Nuclear Department.
17.2.1.4 Director Quality The Director Quality reports directly to the Vice President -
Nuclear and devotes full attention to WCGS quality matters.
He is responsible for the development and for assuring imple-mentation of the operating Quality program.
The Director
' Quality is responsible for staffing the Quality Branch and for assuring that QA and QC personnel are adequately trained and experienced to perform their assigned tasks.
The qualifi-l @
cation requirements for the Director Quality position are:
A bachelor degree in Engineering or related sciences i
plus six years of professional level experience in Nuclear
. Quality Assurance or six years of supervisory experience plus two years of Nuclear Quality Assurance experience, or equiva-lent professional level experience in nuclear quality assurance including six years of supervisory / management experience.
17.2.~1.4.1 Manager Quality Assurance (WCGS) l.
.The Manager Quality Assurance (WCGS),
who reports to the Director Quality, devotes full attention to QA matters.
He
' is ' responsible for. verifying. that an adequate QA program is
[_
. developed and implemented for safety-related activities which
' occur _ at_ the WCGS.
The Manager Quality Assurance (WCGS) is assigned. [ work location] to the Wolf Creek site.
He maintains L
a staff - and provides them with technical and administrative direction.
He' 'is ' responsible for ~ establishing and implement-ing a comprehensive plant site audit program.
The qualifi-
- cations _ of the Manager Quality Assurance (WCGS) are a Bache-lor's Degree in Engineering or-related science and at the time of-, initial ~ core ' loading or appointment to the position and
~will.have four years experience in the field of quality assur-
'ance or equivalent number of years of-nuclear plant experience or combination of the two, at least one year shall be nuclear power-plant' quality assurance implementation experience.
Rev. 15 17.2-4a 1/85 lh, g ' g a 4,_ ',
4 ry
SNUPPS-WC 17.2.1.4.4 Quality Branch Personnel Independence t
The authorities and duties of QA and QC personnel and other organizations performing quality verification functions are clearly established in written procedures.
Such persons have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solu-tions; and to verify corrective action.
Assurance of quality by auditing, inspecting,
- checking, or otherwise verifying program activities is by personnel independent of the indi-vidual or group performing the specific activity.
17.2.1.5 Manager Nuclear Plant Engineering The Manager Nuclear Plant Engineering reports to the Director h) of Engineering and Technical Services for overall program direction.
He is responsible for station modifications, l@
additions, engineering studies, and design reviews which are conducted at the general office or subcontracted by the general office to an outside organization.
17.2.1.6 Manager Nuclear Services 1
The Manager Nuclear Services reports to the Director of Engi-g neering and Technical Services for overall program direction.
of I @
He-is responsible for providing services in the areas licensing, fuels management, fuel procurement, and safety analysis.
He is responsible for home office support of the plant in nuclear engineering, chemistry, health physics, and environmental areas.
17.2.1.7 Director Nuclear Operations The Director Nuclear Operations reports to the Vice President-Nuclear for overall program direction.
He is responsible for g the operations,- training and startup departments.
The Plant
- Manager, the Manager Operations Support, Supervisor Project (7)
Planning and Controls, and the Manager Nuclear Training report to the Director -Nuclear Operations for overall program direc-tion.
The Director Nuclear Operations is also responsible for l@@
preparing those portions of the WCGS operating and maintenance
~ budget not specifically assigned to other divisions.
17.2.1.7.1 Plant Manager The Plant Manager reports to the Director Nuclear Operations. -l @
He is responsible
.Rev. 15
.17.2-5
.1/85 a9 W
- S y
Y
,._ _~ _, -..
.,-._,._,___..__,_--.,.,m.
SNUPPS-WC for the safe operation of the WCGS.
He controls plant activ-lg ities through Superintendents as digcussed in Section 13.1.
- l He has the prime responsibility for safe operation of the plant.
The plant staff, under the direction of the Plant Manager, develops detailed procedures and instructions for testing and operation of the station.
17.2.1.7.2 Startup Manager The Startup Manager reports to the Plant Manager for overall program direction and to the Wolf Creek Site Director -
lb for day-to-day project direction.
He is responsible for the overall direction and administration of the functions and activities required to conduct' the WCGS startup program.
Chapter 14.0 presents a description of the Startup Organiza-tion and delineates the Startup Manager's responsibilities.
When the startup program has concluded, the Startup Organiza-tion will be dissolved.
17.2.1.7.3 Manager Nuclear Training The Manager Nuclear Training will report to the Director Nuclear Operations.
He is responsible for insuring training staff qualifications, including reviewing instructor evalua-tion records with the Training Supervisor and Simulator Supervisor.
He is responsible for reviewing the content of training programs for technical completeness and compliance with regulatory standards.
He is also responsible for auditing the quality of on-site training programs.
The Manager Nuclear Training is also responsible for training programs for Corporate offico perconnel involved in support of WCGS during normal operations, preparedness for response to off-normal incidents, and long-term recovery programs.
17.2.1.7.4 Manager Operations Support The Manager Operations Support reports to the Director Nuclear Operations and is responsible for providing staff support to the Director Nuclear Operations.
The Manager Operations Sup--
l($
port supervises the activities of the Operations Support Group.
He reviews nuclear operational activities and coordi-nates home office support to plant operations.
Rev. 15 17.2-5a 1/85
^.
e
x SNUPPS-WC 17.2.1.8 Director - Purchasing The Director Purchasing reports. administratively to the Group Vice President Administration who reports to the President and Chairman of the Board.
The Director - Purchas-ing also has reporting responsibilities to the Group Vice President - Technical Services for materials, systems, compo-nents and parts (not delegated to outside organizations) that are needed to support WCGS.
He is responsible for issuing purchase orders and contracts, for the commercial content of those documents, the financial / commercial qualification of vendors, and for processing invoices.
lg 17.2.1.9 This Section has been deleted.
17.2.1.10 Safety Review Committees Safety review committees shall be established at the WCGS (the Plant Safety Review Committee) and at the KG&E General Office (the Nuclear Safety Review Committee) to provide independent review of those items required by the WCGS Technical Specifi-cations.
Committee membership and duties are described in the Administrative Controls Section of the Technical Specifica-tions.
e Rev. 15 17.2-6 1/85 a-
..~. :. 2 ~
a
--,--.-,.-._,, - --.--._~, -,,,.----,
f SNUPPS-WC 17.2.1.11 Manager Quality First The Manager Quality First reports directly to the Group Vice President-Technical Services.
He is responsible for directing the Quality First Program which provides an independent organ-ization to investigate safety and quality concerns.
7 17.2.1.12 Manager Construction The Manager Construction reports directly to the Group Vice President - Nuclear.
He provides Construction Support to the project.
Rev. 15 17.2-6a 1/85
SNUPPS-WC 17.2.2 QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope KG&E has established an operating Quality program which controls activities affecting quality.
The program encom-passes those quality activities necessary to support the operating phase of the WCGS.
The total operating Quality program complies with 10 CFR 50, Appendix B,
" Quality Assur-ance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and generally follows the guidance of Regulatory Guide 1.33.
Several alternate methods of meeting Regulatory Guide 1.33 are described in this chapter and in Appendix 3A.
17.2.2.2 Identification of Safety-Related Items The scope and activity applicability of the operating Quality program are described in Section 17.2.0.
Safety-related structures, systems, and components are identified in Table 3.2-1 of the Standard Plant FSAR.
This list includes struc-tures, systems, and components identified as safety-related during the design and construction phase and may be modified as required during operations, consistent with their impor-tance to nuclear safety.
Table 3.2-1 is maintained current by the Manager Nuclear Services with changes to the table being approved by the Director Quality, Director of Engineering and Technical Services, and Director Nuclear Operations.
During the operational phase the operating Quality program is the governing quality assurance program for safety-related structures, systems, components and consumables.
The programs identified under the " Quality Assurance" heading of Table 3.2-1 are those utilized during the design and construction phase.
Should safety-related equipment or services be pro-cured from Bechtel, Westinghouse, or others during the oper-ating phase, quality assurance requirements will be determined and imposed in accordance with Sections 17.2.4 and 17.2.7.
17.2.2.3 Operating Quality Program Implementation l
The operating Quality program shall be implemented at least 90 days prior to fuel loading.
The operating Quality program shall be implemented throughout the operating life of the WCGS.
Special equipment, environmental conditions, skills, or e
processes will be provided as necessary to demonstrate effec-tive implementation of the operating Quality program.
Implementation of the operating Quality program by KG&E is directed towards assurance that operating phase activities and maintenance activities are conducted under controlled condi-tions and in compliance with applicable regulatory require-ments, including 10 CFR 50, Appendix B.
Management responsi-ble for conducting safety-related activities shall be respon-sible for providing approved procedures prior to initiating i
the activity.
i j
17.2-7 Rev. 15
- 3.,
01/85-u
- a. w
+
v~~.nw
~
SNUPPS-WC j
with new regulatory requirements.
Design changes are defined to mean 1) planned changes in the basic plant design which modify.the plant response, general design criteria, and speci-fication requirements; 2) the substitution of equivalent 16) hardware or the substitution of nonsafety-related parts or components into safety-related components or systems; and g 3) any noneditorial change to a design document.
Changes in the ' WCGS basic design shall be aimed at improving safety, performance, maintainability, reliability, or inspectability.
- An ' engineering evaluation assures that these changes are con-sistent. with the performance requirements specified in existing design documents.
Procedures shall specify requirements for the review and approval of design changes by the organizations that performed the original design, if appropriate.
Design activities may be delegated.to others provided they have access to background and technical information.
Design changes shall be commun-icated to appropriate plant personnel when such changes may affect the performance of their duties.
l 17.2.3.8 Design Review Committees Independent of the responsibilities of the design organiza-tion, the requirements of the Plant Safety Review Committee (PSRC). and the Nuclear Safety Review Committee (NSRC) as specified in the Administrative Controls Section of the Technical Specifications, shall be satisfied.
Design changes lh which involve a modification or a ' creation of basic design criteria require a safety evaluation and review, and con-currence by the PSRC.
Design changes _ which involve the sub-l M stitution - of hardware require a safety. evaluation by the PSRC and approval by the ~ Plant Manager; however, those changes which involve an unreviewed safety question or change in Technical Specifications also require a review and concurrence by the NSRC.Manager Nuclear Plant Engineering shall perform or l h When design is performed by an outside organiza-tion, the
~ coordinate-a review for operability,. maintainability, inspectability,
'SAR commitment compatability, and design requirements imposed by plant equipment.
In
- addition, the, Manager Nuclear Plant Engineering shall identify and control design interfaces and coordinate the design process between. internal divisions and the outside organization (s).
When required, safety analyses which consider the effect of,
p the design'.~ as described in - the design' documents may be per-
' formed by KG&E or outside organizations.
These. analyses shall provide the basis for the PSRC safety evaluations which are Rev. 15
~
17.2-14 1/85
~F w
a a f
=y
< M.h fd_A
'v afk W hmW vwi
SNUPPS-WC 4.
Acceptance and rejection crite'ria 5.
Identifying required procedures, drawings and specifications, and revisions 6.
Recording inspector or data recorder and the results of the inspection operation 7.
Specifying necessary measuring and test equip-ment, including accuracy requirements.
8.
Evaluation of the inspection results and the person performing the evaluation.
17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and person-nel shall be utilized as a control if inspection of processed
)
items is impossible or disadvantageous.
Both inspection and process. monitoring shall be provided when control is inade-quate without _both.
A suitable level of confidence in structures,
- systems, or components on which maintenance or modifications have been performed may be attained by inspec-tion., As appropriate, an augmented inspection program shall be implemented. until such time as a suitable level of per-formance has been demonstrated.
Process monitoring of ongoing activities at the WCGS shall be at intervals based on the status and safety importance of the activities.
Guidelines shall be established to indicate the minimum frequency of_ process monitoring for each ongaing activity and to provide a basis for subsequent monitoring planning.
The monitoring of_ processes shall. be performed to verify that quality affecting activities are being performed in accordance with. documented instructions, procedures,
- drawings, and specification.
17.2.10.4 -Inservice Inspection Required inservice inspection or process. monitoring of struc-tures, systems, or components shall be planned and executed.
Inspection methods shall'be established and executed to verify that the characteristics of an item continue to remain within Y
specified limits.
The Manager Nuclear Plant Engineering shall be responsible for assuring the. development of a preservice and inservice-
~ (PSI /ISI)_ inspection program, procedures and reference pre-service : and inservice examination plans; the - updating of-the reference plans to reflect as-built conditions, the tech-nical requirements _ of the applicable code edition and addenda and the securing of inspection and consulting services.
The
' Plant Manager shall direct the performance of preservice/in-service inspection of pressure retaining components and their h
- supports.-
Rev. 15 '
17.2-38
, 01/85-E r% $ NA e-
['
'h M
'9, Q
h-
l SNUPPS-WC The services of an outside organization may be secured for the conduct of PSI /ISI inspections.
The Plant Manager shall al so be responsible for the development and performance of the Q
PSI /ISI testing of pumps and valves as described in Section 17.2.11.
17.2.10.5 Acceotance The acceptance of an item shall be documented by authorized personnel.
Modification,
- repair, or replacement of items performed subsequent to final inspection shall require rein-4 spection or retest, as appropriate, to verify acceptability.
17.2.10.6 Qualification of Inspection Personnel KG&E personnel or personnel from outside organizations shall perform acceptance inspection activities and shall be quali-fled within their respective areas of responsibility.
The assignment of plant acceptance inspection personnel shall be under the direction and control of the Quality Branch.
. Qualification of. KG&E inspection personnel (Exclusive of NDE) shall_not be limited by company position and shall be defined in levels of capability.
The number of levels established for each type of inspector shall be at least one but no more than three.
Inspection assignments shall be consistent with the certification of an individual.
Inspections associated with normal operations of the plant such as routine mainte-nance, surveillance, and tests) shall be performed by indivi-duals other than those who performed or directly supervised the work and may be within the same group, if the following controls are met:
1.
The quality of the work is demonstrated through a functional test when the activity involves breaching a pressure retaining item.
2.
Inspection procedures, and qualifications of inspection personnel are reviewed and found acceptable by the Quality Branch prior to initiating the inspection.
17.2.10.7 Qua.lification of NDE Personnel Nondestructive examination functions shall be accomplished by plant personnel or outside organizations.
Personnel involved in the ' performance, evaluation, or supervision of nondestruc-
'tive examinations shall meet the qualification requirements specified ' in SNT-TC-1A.
The certification of nondestructive testing personnel shall -be to one of three basic levels of qualification.
17.2-39 Rev. 15 01/85
..a
.msm m_
a
SNUPPS-WC 17.2.15 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS 17.2.15.1 Scope Nonconformances are any deficiency in characteristics, docu-mentation, or procedure which renders the quality of an item unacceptable or indeterminate.
Nonconformances, therefore, include material deficiencies, malfunctioning or inoperative structures, systems and components, and departures from speci-fled procedural requirements which impact the quality of an item.
Nonconforming activities which have not resulted in hardware nonconformances (i.e.,
programatic or procedural deficiencies which do not impact the quality of an item), are corrected in accordance with Chapter 17.2.16, Corrective Action.
17.2.15.2 Nonconformance Controls Nonconformances identified under the KG&E Quality Program shall be identified, documented, controlled, dispositioned and corrected in accordance with approved procedures.
These mea-sures shall provide for the notification of affected parties and controls to prevent the inadvertent use of nonconforming items.
Nonconformances shall be controlled by report documentation, tagging, marking, logging, or physical segregation.
Noncon-formcnces shall be documented on records which identify the nonconforming condition, record the disposition, and register l @
the signature of an appropriate approval authority.
Noncon-formances shall be reworked, rejected, repaired, or accepted.
Repaired and reworked items shall be reinspected in accordance with applicable procedures.
Reinspection results and opera-1 O tional data, gathered subsequent to repair or rework, are documented or referenced on nonconformance, test or inspec-l @
tion documentation.
Measures shall be established to control the conditional re-lease of nonconformances for which correction is pending and a technical evaluation indicates that installation and/or test-ing, will not adversely affect nor preclude identification and b
correction of the nonconformance.
A conditional release to proceed installation and/or with testing of a system or sub-system with outstanding nonconformances will consider the nature of the nonconformance, its effect on installation and/
or testing and the need for supplemental tests or inspections h after correction of the nonconformance.
Conditional release evaluations shall be documented.
Nonconforming items required for Technical Specification h Operability shall only be released for use through the com-pletion of a Plant Modification Request (PMR).
Rev. 15 17.2-50 1/85
^ mirwi 4W i,
ev
-n-r
-e r,
2
.-----,-..---w
-w-=
,-,e.,-s,
-r e,
,.g-
,--,e.-.,.
1 SNUPPS-WC 17.2.15.3 Reporting Methods Nonconformance Reports, Work Requests, and Deficient Document Notices shall be employed to document nonconformances.
Nonconformance Reports shall be used to document nonconform-ing materials, parts, or components under warehouse control.
Work Requests may be used to document nonconforming conditions identified after issue from the warehouse.
Nonconformance Reports and Work Requests requiring "Use-As-Is" or ~" Repair" dispositions shall be reviewed and dispositioned h by the responsible design authority.
Deficient Document Notices shall be used to document minor documentation-related nonconformances which are identified at time of receipt inspection.
Documentation discrepancies identified after receipt inspec-tion that render the quality of hardware indeterminate will (f) be documented using an NCR.
17.2.15.4 Disposition Procedures shall prescribe the individuals or groups assigned the responsibility and authority to approve the disposition of nonconformances.
Nonconformance disposition categories are:
1.
" Reject" - the process by which a nonconforming item is rejected for use and either scrapped, returned to
- vendor, or downgraded to allow for use in a Non-Q System.
2.
" Rework" - the process by which a
nonconforming Q
item is made to conform to a prior v_v specified requirement by completion, remachining, reassembling or other corrective means.
3.
" Repair" - the process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safely is unimpaired, even though that item still may not conform to the original requirement.
4.
"Use-as-is" - A disposition which may be imposed (i.e.,
Accept)for a nonconformance when it can be established that the discrepancy will result in no adverse conditions 6
Rev. 15 s
17.2-51 1/85
~
" fw M
l l
SNUPPS-WC l
and that the item under consideration will continue to meet all engineering functional requirements including h performance, maintainability, fit and safety.
" Repair" and "Use-as-is" dispositions shall be approved by the responsible design authority as prescribed in procedures.
This authority shall be an organization which has demonstrated competence in the specific area, has an adequate understanding of the requirements and has access to pertinent background information.
Prior to implementation, dispositions may, for the preopera-tional test phase, and shall, for the Startup and Operations Phase, be independently reviewed by the Quality Branch.
17.2.15.5 Procurement Controls Plant and other KG&E organization procedures shall prescribe measures for the control and disposition of KG&E purchased Rev. 15 17.2-51a 1/85 n
SNUPPS-WC items which are identified by outside organizations as non-conforming.
Procurement documents specify those nonconfor-mances which shall be submitted to KG&E for approval of the recommended disposition.
Actions taken in response to these nonconformances shall require documentation and shall be for-warded to KG&E along with the hardware and accompanying quality verification documentation.
Nuclear Plant Engineer-ing shall approve the recommended disposition of nonconform-ances relating to KG&E initiated procurement requirements.
The Quality Branch staff shall be responsible for assuring the processing of these supplier-recommended dispositions.
The disposition of a nonconformance which involves the design requirements shall be treated as a design change and, there-fore, approved by the responsible design authority.
17.2.15.6 Reportable Nonconformances Nonconformances shall be evaluated for reportability to the NRC under 10 CFR 21.
All nonconformances identified as re-portable shall be reviewed by the PSRC and NSRC.
17.2.15.7 Trend Analysis Nonconformance documentation shall be analyzed by Quality Branch personnel for identification of potential unsatisfac-tory programatic quality trends.
The results of these l@
analyses shall be reported to management.
Significant adverse l@
quality program trends shall be handled in accordance with Section 17.2.16.
-Rev. 15 17.2-52 01/85 y
=
w-
- --"e~
u SNUPPS-WC 17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope A. records system governing the collection, storage, and main-
.tenance of records shall be established by KG&E and shall be in compliance with the standards and Regulatory Guides ident-ified in Table 17.2-3.
At a minimum, the records system shall apply to : operating phase records associated with operating Quality program governed activities when records are required to ~ either demonstrate compliance with licensing commitment or finished documentary. evidence of the quality of items and activities affecting quality.
All such records shall be considered QA records and shall be
- legible, complete, adequately identifiable to the item or activity involved and readily retrievable.
Quality' Assurance records include but are not limited to oper-ating logs; maintenance and modification procedures and in-spection results; reportable occurrences; results of monitor-ing Land reviews; inspections,
- tests, audits, and material
-analyses; qualification of personnel, procedures, and equip-ment; records required by Technical Specifications; and other documentation - including drawings, specifications, procurement documents, nonconformance documentation, corrective action requests, procedures, and calibration procedures and reports required to demonstrate compliance with license commitments.
17.2.17.2 -Responsibilities A records system shall be established by the plant and other KGirE organizations and 'shall-be controlled in accordance with written-procedures.
Implementing procedures shall address records administration; receipt of records; storage, preser-vation, and safekeeping of records; record retrieval; and the disposition of records in accordance with requirements identi-fied in Table '17.2-3.
The Manager. Management Systems is responsible for assuring. the handling and maintenance-of Quality Assurance records generated, received, and stored at the home office.. The Quality Branch shall audit the. home l@
of fice - and the ~ WCGS Quality Assurance record storage systems to verify their. ef fectiveness.
17.2.17.3 Records Index The - requirements for Lrecords administration shall specify that
- Quality Assurance records be listed in an index.
The index shall be established prior to the receipt of records and shall indicate ~the location of records.
. Distributing and handling Rev. 15 17.2-55 01/85
e r
SNUPPS-WC TABIE 17.2-3 (Cont'd)
REGUIATORY GUIDS ENDORSED STANDARD / CODE 1.74,*
" Quality Assurance Terms and ANSI N45.2.10 - 1973 Definitions" (Rev. O, 2/74) 1.88,*
" Collection, Storage, and Main-ANSI N45.2.9 - 1974 tenance of Nuclear Power Plant Quality Assurance Records" (Rev. 2, 10/76) 1.94,*
" Quality Assurance Requirements ANSI N45.2.5 - 1974 for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Can-struction Phase of Nuclear Power Plants" (Rev. 1, 4/76) 1.116,*
" Quality Assurance Requirements ANSI N45.2.8 - 1975 for Installation, Inspection and Testing of I4r.hanical Equipment and Systems" (Rev. 0-R, 6/76 revised 5/77) 1.123,
" Quality Assurance Ibquirements ANSI N45.2.13 - 1976 for Control of Procurement of Items and Services for Nuclear Power Plants" (Rev. 1, 7/77) 1.144, Auditing of Quality Assurance ANSI N45.2.12 - 1977 Programs for Nuclear Power Plants (Rev. 1, 9/80) 1.146
" Qualification of Quality Assurance ANSI N45.2.23 - 1978 Program Audit Personnel for Nuclear Power Plants" (8/80)
For clarifications and alternate methods for complying with these Regulatory Guides, see Appendix ")A.
Rev. 15 01/85 As,
GE:
.iE
- =
<s!
5 as-Us=I*I E
I' a O.
v Gi!
=8E 1ji -li1 l,1 l-ll3 e
T i
5 E
E
.E.
s::E E.g i IEI' Sig WB.
.gj
---v E
g:
IE!5 I$
IE!j-
!EE 3
EW=E 3:=
ySg us.
(EI-si 5C5 W!k
- !st-Ell i
t I" E
.E.
E I
al!s if I!!
i Eg:
i of I
5 89 T T T Is E
==
8 rg rz r- =r v
Ela lI5 EE E
Es EE I Ei Ej IE I s!E E
l El 25 g
a e
E!!
su s
T s
e e
l1=:
= = :.d a:
sa a
n I-a 8
at T +TT T
y s
E a 8 55
- 8E 2!
i g 2:r
-- sI!
ei
=
0.m i!)
gri pg,
==a
.=
=
ai
[g g,
a-ggy
!gg!
j { g, gg=
l
!s 3
g i
gg jgIi l i
g Ej "I
7 gX fa g s!n a
sag n
N
- !g-8-
s!I I Esi 2E-
!-l ei lW s-5 8
el i -[ 3
. [".
^
[5 5
.g n3: e a si-y ag a v
ul r egE 15 g 8
m I3 l888
- Ig5g, gg E
g s 8I.g g =g,
e av as I
5 E EI gel 5 EU$
- kljl a al 2g
- l. :.
a
--